APSCo UK April Legal Updates

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By APSCo United Kingdom April 13, 2026 3 minutes read time

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The latest APSCo legal updates for April 2026.

W/C 27th April

Supply Teachers & Education Recruitment Framework - Go-Live Date and Compliance+ Deadlines

Following a recent discussion between APSCo MD Sam Hurley and John Wilson from the Crown Commercial Service (CCS) (now known as the Government Commercial Agency (GCA)), further clarity has been provided on the rollout of the new Supply Teachers & Education Recruitment framework.

The framework is expected to go live on 1 May 2026, subject to any legal challenges. Recruitment businesses that have been successfully awarded a place on the framework and have already passed their Compliance+ audit can now submit their Compliance+ audit pass certificate (along with their Cyber Essentials, Insurance etc) directly to the GCA in advance of go-live.

Those who have not yet completed the audit will have a six-month window from the go-live date to achieve Compliance+ accreditation.

Importantly, suppliers will only be activated on the framework once the GCA has received a valid Compliance+ pass certificate. In practical terms, this means agencies have until October 2026 to complete the audit process and secure their place on the framework.

The DfE has also issued a guidance on supply staff mandate which lays out the maximum fees suppliers within the GCA framework will be able to charge.

Further information can be found in our APSCo Update through our What’s New page.

APSCo Inside Legal and Compliance – Q2 2026

As part of our service to members, APSCo has produced the latest edition of our Inside Series: Legal & Compliance - Board Briefing Q2 2026.

Inside Legal and Compliance aims to provide members’ boards, legal and compliance teams with a steer on upcoming legal changes and guidance affecting the professional recruitment sector to enable a proactive response and potentially competitive advantage.

The latest Legal and Compliance Inside Series is available on our website in the Inside Legal and Compliance section and on our What’s New page.

W/C 20th April

1) HSE - Consultation on proposed changes to RIDDOR

The Health and Safety Executive (HSE) launched a consultation on proposed changes to Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) aimed to modernise how work-related injuries, ill health and dangerous incidents are reported at work. The HSE is consulting on legislative and non-legislative changes covering:

Clarification of definitions in Regulation 2 of RIDDOR,
Revision of the list of occupational diseases in Regulation 8 of RIDDOR,
Expansion of the scope of accepted "diagnosis" in Regulation 2 of RIDDOR,
Revision of the list of dangerous occurrences in Schedule 2 of RIDDOR,
Improvement and simplification of the RIDDOR reporting process.

The consultation is open until 30 June 2026 and can be answered using the HSE online survey.

2) Home Office - Consultation on draft code of practice for employers: avoiding unlawful discrimination when conducting Right to Work checks

The Home Office is seeking views on amendments to the Code of Practice for employers on avoiding unlawful discrimination while preventing illegal working. Amongst the proposed changes, the Home Office is considering amending the definition of Employer to broaden the scope to a person who employs an individual:

under a contract of employment (a contract of service or apprenticeship)
under a worker’s contract
as an individual sub-contractor, or
an online matching service providing the details of an individual who is a service provider to potential clients or customers.

The consultation is open until 29 April 2026 and feedback can be sent to righttorentandrighttowork@homeoffice.gov.uk

W/C 13th April

1) ICO - Report, guidance and consultation on Automated decision-making in recruitment

The Information Commissioner's Office (ICO) published a report and associated draft guidance on AI automation and the use of automated decision-making (ADM) systems.

The report suggests that 70% of employers anticipate increasing their use of AI and automation in their recruitment process over the next five years. To ensure that employers put proper safeguards in place to protect people and comply with Data Protection law, the ICO issued a draft guidance for employers when relying on ADM during the recruitment process.

To finalise the guidance, the ICO is seeking views on the following points:

Your general and specific views on the draft guidance,
Your experience,
Your views on the daft impact assessment,
Your views on the costs and benefits of the draft guidance to your organisation.

The consultation is open until 29 May 2026 and can be answered by completing the ICO's online survey.

You can access the ICO report here, and the guidance on ADM is accessible here.

2) APSCo Update - Statutory Rate Increases 2026-2027

Following the announced rate increases effective from 1 April 2026, APSCo created a summary table outlining the main changes for:

The National Minimum Wage and National Living Wage;
Statutory Maternity, Paternity, Adoption, Parental , Bereavement, and Neonatal care pay rate; and
Statutory Sick Pay rate.

You can access our Legal Update here.